The Internal Revenue Services (IRS) issued Notice 2014-67 on Oct. 24, 2014, to “amplify” Revenue Procedure 97-13 by (i) creating a new five-year safe harbor for management contracts, and (ii) expanding the permitted types of productivity awards allowed.

Rev. Proc. 97-13 describes certain “safe harbor” arrangements that tax-exempt healthcare facilities financed with tax-free bonds can rely on to ensure any “management, service or incentive payment contract” between the facility and a service provider does not result in private business use. Many physician service agreements fall within this category.

The HHS OIG released its Work Plan for FY 2014 three months ago and is hard at work investigating the issues highlighted in its annual publication. The OIG’s annual Work Plan lists current and new projects it will address during 2014, and is an excellent source for healthcare facilities to use in identifying potential compliance risk areas. The Work Plan has a number of items that impact children’s hospitals. Whether you immediately added these issues to your organization’s list of potential risk areas or still haven’t had the opportunity to review this year’s Work Plan, we recommend that you do not lose sight of these issues.

This article was originally published by the American Health Lawyers Association. Copyright 2014, American Health Lawyers Association, Washington, DC.  Reprint permission granted.

Recently, the Obama Administration released its fiscal year 2015 budget proposal, which includes several proposals of special interest to children’s hospitals. The Budget proposes several new and strategic investments in the nation’s health care